In Blake v. Neighborhood Housing Services, N.Y. City, the New York Court of Appeals addressed whether a worker injured while using a ladder could recover under Labor Law § 240(1) when the ladder provided proper protection and the worker’s own actions were the only cause of the fall. This case clarified the limits of liability under the statute and reaffirmed that not every fall from a ladder results in an automatic finding of liability. The court focused on whether the defendant violated the statute and whether that violation caused the injury.
Background Facts
Rupert Blake owned a contracting company and was hired to perform renovation work at a two-family home in the Bronx. The homeowner had received financing from Neighborhood Housing Services of New York City (NHS), a nonprofit lender. NHS provided a work estimate and a list of possible contractors. The homeowner selected Blake, and NHS had no further involvement in directing the work.